Object

Representation ID: 5037

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

Strategic Objective 11
the Green Infrastructure evidence being used by the Council is far too vague, unclear, meaningless, insufficiently robust, and fails to respond effectively to paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform Local Plan preparation and highly contentious spatial planning policy considerations, which will deliver thousands of new homes immediately alongside highly sensitive landscape-scale wildlife corridors. Such as the South Staffordshire Railway Walk in Lower Penn, which contains critically important bat roosts within areas of sensitive deciduous broadleaved woodland. The Council is taking forward an unsound policy (based on highly questionable, vague, meaningless and insufficiently robust evidence) which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021). Object to the continued poor quality of the evidence base being used by the Council to support Local Plan preparation.
The Local Plan is not being informed by sufficiently robust green infrastructure evidence. In particular, robustly-based wildlife corridor green infrastructure assessments as required by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The emerging Local Plan Review assumptions are therefore based on flawed, insufficiently robust and missing evidence.